Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The AT dismissed the appeal, holding that the Appellant's placement business constituted the scheduled offence and generated proceeds of crime. Statements under Section 50 PMLA and ancillary investigations established that domestic workers were placed on wages below the statutory minima and that some employees were underage; the Appellant's denial lacked evidential support. Conveyance documents offered did not substantiate the alleged Faridabad plot sale; consequently, the AT found that Rs. 9,94,290 of the impugned property was funded by proceeds of crime. The Tribunal also refused to waive occupation and user charges previously imposed to permit continued possession pending trial. Attachment of the property was therefore sustained pending conviction.
The AT dismissed the appeal, holding that the Appellant's placement business constituted the scheduled offence and generated proceeds of crime. Statements under Section 50 PMLA and ancillary investigations established that domestic workers were placed on wages below the statutory minima and that some employees were underage; the Appellant's denial lacked evidential support. Conveyance documents offered did not substantiate the alleged Faridabad plot sale; consequently, the AT found that Rs. 9,94,290 of the impugned property was funded by proceeds of crime. The Tribunal also refused to waive occupation and user charges previously imposed to permit continued possession pending trial. Attachment of the property was therefore sustained pending conviction.
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